Memorandum Findings of Fact and Opinion
This proceeding involves a deficiency of $91,184.05 for the fiscal year ended September 30, 1946. In an amended answer the respondent asked that the deficiency be increased to $93,782.27. The questions in issue are (1) whether the petitioner realized a taxable gain upon the transfer of a retail liquor business to a newly organized corporation in exchange for its capital stock, and (2) whether a payment which petitioner received...
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